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HomeMy WebLinkAbout09-8551RUSSELL FLUEVOG, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. ?Yc ?? C ?? 1 ctM CIVIL- DIVORCE PATRICIA FLUEVOG, Defendant NOTICE TO DEFEND You have been sued in Court. If you wish to defend against the claims set forth in the following pages, you must take prompt action. You are warned that if you fail to do so, the case may proceed without you and a decree of divorce or annulment may be entered against you by the court. A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage, you may request marriage counseling. A list of marriage counselors is available in the Office of the Prothonotary at the first floor in the Cumberland County Courthouse, 1 Courthouse Square, Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY, DIVISION OF PROPERTY, LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED, YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle, Pennsylvania 17013 Telephone (717) 249-3166 RUSSELL FLUEVOG, IN THE COURT OF'COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. . NO. © G- ?S 1 &-.d lvr~. CIVIL - DIVORCE PATRICIA FLUEVOG, Defendant COMPLAINT IN DIVORCE AND NOW, comes the Plaintiff, Russell Fluevog, by his attorney, John M. Kerr, Esquire, pursuant to Section 3301(c) & 3301 (d) of the Pennsylvania Divorce Code, and seeks to obtain a Decree in Divorce from the Defendant, Patricia Fluevog, upon the grounds set forth: COUNT I - NO-FAULT DIVORCE UNDER 3301(c) or 3301(d) 1. The Plaintiff, Russell Fluevog, is an adult individual residing at 14 Sunset Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Defendant, Patricia Fluevog, is an adult individual residing at 6 Wagner Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Law Offi f otul M.?err 5020 Ritter Road Suite log Mechanicsburg, PA 17055 PHoNs: 717.766.4008 FAx: 717.766.4066 Pennsylvania for at least six (6) months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 28, 2004 in Carlisle, Pennsylvania. 5. Plaintiff separated from Defendant on November 27, 2009. 6. There have been no prior actions of divorce or annulment between the parties in this or any other jurisdiction. 7. The Plaintiff and Defendant are both citizens of the United States of America. 8. The Defendant is not a member of the United States Armed Forces. 9. The cause of action and section of Divorce Code under which Plaintiff is proceeding is that the marriage is irretrievably broken under 23 Pa. Const. Stat. §3301(c) or 3301(d). 10. Plaintiff requests this Honorable Court to enter a decree of divorce pursuant to Section 3301(c) or 3301 (d) of the Divorce Code. WHEREFORE, it is requested that the Court enter a decree of divorce under either §§ 3301(c) or 3301(d) of the Divorce Code. Respectfully submitted, t ?nn M. Kerr, Esquire I.D. #26414 Law Office of John M. Kerr, Esquire 5020 Ritter Road Suite 109 Mechanicsburg, PA 17055 (717) 766-4008 kerrlaw(@ mcast net Dated: December 11, 2009 oh.?en YL':7M" 5020 Ritter Road Suite 109 MecharUcsburg.PA 17055 PRONe: 717.766.4005 FAx: 717.766.4066 F VERIFICATION The undersigned hereby states that he is the Plaintiff in the foregoing Divorce Action and, as such, is authorized to execute this Verification, and that any factual statements contained in the preceding Complaint in Divorce are true and correct to the best of his knowledge, information and belief. He understands that any false statements are subject to the penalties prescribed at 18 Pa.C.S.§4904, relating to unsworn falsification to authorities. Russell Fluevog 2099 QEC ? l P? 12' 1 9 ', jiff t G 6 R-N a'3y?"5? of cc/ 'sf Davi( Buell d p Renee 7(, Simpson Prothonotary � ;: y 1st Deputy Prothonotary 9vtorrow �irkS. Sohonage, ESQ, Irene E. Solicitor 1750 rd Deputy Prothonotary Office of the Prothonotary Cumberland County, Pennsylvania • 09 -ecs1 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 291" DAY OF OCTOBER, 2013,AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE—THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square • Suite 100 • Carlisle, PA 17013 • (717)240-6195 • cEa.x(717)240-6573 0 DEC 1.19 111 a a_.Ei Lfi `iii LL i-i 1 °�' PENNSYLVANIA RUSSELL ANDREW FLUEVOG : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. :NO. 2009-8551 CIVIL TERM PATRICIA ANN FLUEVOG, : CIVIL ACTION -LAW Defendant : IN DIVORCE PETITION FOR REINSTATEMENT OF DIVORCE ACTION AND NOW, comes the Petitioner, Patricia Ann Fluevog, who files this Petition to Reinstate the Divorce Action, Docket No. 2009-8551: 1. The Petitioner/Defendant, Patricia Ann Fluevog, is an adult individual who currently resides at 30 Village Court, Mechanicsburg, Cumberland County, Pennsylvania 17050. 2. The Respondent/Plaintiff, Russell Andrew Fluevog, is an adult individual who currently resides at 6 Wagner Drive, Mechanicsburg, Cumberland County, Pennsylvania 17050. 3. The Respondent/Plaintiff filed a Divorce Action on December 11, 2009. 4. Petitioner/Defendant contacted the Prothonotary's Office in Cumberland County with regard to the case on or about August 2, 2013 and was told that the case was on the purge list and that if nothing was filed prior to December 31, 2013 the case would be purged. 5. Petitioner/Defendant contacted Attorney Fiona K. Fadness to enter her appearance for her in this Divorce case, stating that something needed to be filed by December 31, 2013, and Attorney Fadness filed an Entry of Appearance and a Statement of Intention to Proceed on November 19, 2013. (See Exhibit A and B). 6. The Prothonotary's Office returned both filed documents stating that they should not have accepted them for filing since the deadline to respond to the notice of purging/dismissal was October 29, 2013. 7. Petitioner/Defendant never received a letter from the Prothonotary's Office indicating that the case was on the purge list for 2013. 8. The Prothonotary's Office indicated to Attorney Fiona K. Fadness, Esq. on December 18, 2013 that they mailed the letter informing Petitioner/Defendant that if nothing was filed on the case by October 29, 2013, the case would be purged for inactivity to the following address: 6 Wagner Drive, Mechanicsburg, PA 17050 on August 30, 2013. 9. The Prothonotary's Office indicated that they did not receive the letter back in the mail for non-delivery. 8. Petitioner/ Defendant has not lived at the marital residence, 6 Wagner Drive, Mechanicsburg, PA 17050 since approximately the end of August 2011. 9. Respondent/Plaintiff resides in the marital residence, 6 Wagner Drive, Mechanicsburg, PA 17050. 10. Petitioner/Defendant did not receive the notice with regard to the required response date for this Divorce action. 11. Petitioner/Defendant believes and therefore avers that Respondent/Plaintiff did not forward the mail to her and purposely kept this information from her. 12. Two years have past since the date of separation on or about August 31, 2011, and Petitioner/Defendant would like to have the opportunity to proceed with the divorce and request a divorce decree be entered. , WHEREFORE, the Petitioner, Patiricia Ann Fluevog, respectfully requests your Honorable Court to enter an Order Reinstating the Divorce Action. Respectfully submitted, Date: / Z 19-13 iona K. Fadness, Esq. Attorney for the Petitioner 212 Barnett Street New Bloomfield, PA 17068 (717) 991-1382 - Phone (717) 685-9907—Fax VERIFICATION I verify that the statements made in the foregoing Complaint/are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. § 4904, relating to unsworn falsification to authorities. / Patricia Ann Fluevog, Petitioner CERTIFICATE OF SERVICE I certify that on this /? day of December, 2013, a copy of the Petition for Reinstatement of Divorce Action was served upon the person indicated below via first-class mail, postage-prepaid: John M. Kerr,Esquire Attorney for Plaintiff/Respondent 5020 Ritter Road, Ste 104 Mechanicsburg, PA 17055 Fiona K. Fadness, Esq. Attorney for the Petitioner 212 Barnett Street New Bloomfield, PA 17068 (717) 991-1382 -Phone (717) 685-9907—Fax Fiona K. Fadness,Esquire i,E r R O T ri oNo 1 ; Attorney I.D.No. 65283 ' �0� r 2c 7 CUMBERLAND 212 BarnetCUMBERLAND C���COUNTY , New Bloomfield,PA 17068 PENNSYLVANIA D OU 717-991-1382 717-685-9907(FAX) fklesquire @aol.com Attorney for Defendant Patricia Ann Fluevog RUSSLL ANDREW FLUEVOG : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA vs. : NO.2009-8551 CIVIL TERM PATRICIA ANN FLUEVOG, : CIVIL ACTION—LAW Defendant : IN DIVORCE ENTRY OF APPEARANCE Please enter my appearance in the above-captioned divorce case for Defendant,Patricia Ann Fluevog. Respectfully submitted, Date: 310 l9 ,2013 By: •----� ✓, Fiona K. ess,Esquire Attorney I.D.#65283 212 Barnett Street New Bloomfield, PA 17068 717-991-1382 717-685-9907(FAX) fklesquire @aol.com Attorney for Defendant, Patricia Ann Fluevog Fiona K. Fadness,Esquire Attorney I.D.No. 65283 212 Barnett Street New Bloomfield,PA 17068 717-991-1382 717-685-9907 (FAX) fklesquire@aol.com Attorney for Defendant Patricia Ann Fluevog RUSSLL ANDREW FLUEVOG : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA vs. : NO. 2009-8551 CIVIL TERM PATRICIA ANN FLUEVOG, : CIVIL ACTION—LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this oil day of t , a-- 2013, I hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mail at Lemoyne,Pennsylvania,postage prepaid,addressed to: John M.Kerr,Esq. John Kerr Law P.0 5020 Ritter Rd.,#104 Mechanicsburg,PA 17055 Counsel for Defendant By: Fiona K. adness,Esq. • ..J-slt' I rC Fiona K. Fadness,Esquire T HR OTHONOTA• Attorney I.D.No. 65283 2013 NOV 1 9 PM 2: 37 212 Barnett Street New Bloomfield,PA 17068 CUMBERLAND COUNTY 717-991-1382 PENNSYLVANIA 717-685-9907 (FAX) flclesquire@aol.corn Attorney for Defendant Patricia Ann Fluevog RUSSLL ANDREW FLUEVOG : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA vs. : NO. 2009-8551 CIVIL TERM PATRICIA ANN FLUEVOG, • CIVIL ACTION—LAW Defendant : IN DIVORCE STATEMENT OF INTENTION TO PROCEED TO THE COURT: Defendant,Patricia Ann Fluevog, intends to proceed with the above-captioned matter. Respectfully submitted, Date: .. /9 ,2013 By: Iona K. _' ess, squire Attorney I.D. # 65283 212 Barnett Street New Bloomfield,PA 17068 717-991-1382 717-685-9907 (FAX) fldesquire @aol.com Attorney for Defendant, Patricia Ann Fluevog • Fiona K. Fadness,Esquire Attorney I.D.No. 65283 212 Barnett Street New Bloomfield,PA 17068 717-991-1382 717-685-9907(FAX) tk1esquire @aol.com Attorney for Defendant Patricia Ann Fluevog RUSSLL ANDREW FLUEVOG • IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA vs. : NO.2009-8551 CIVIL TERM PATRICIA ANN FLUEVOG, : CIVIL ACTION—LAW Defendant : IN DIVORCE CERTIFICATE OF SERVICE AND NOW, this /9'14 day of gore. . - , 2013, I hereby certify that I have served a copy of the within document on the following by depositing a true and correct copy of the same in the U.S. Mail at Lemoyne,Pennsylvania,postage prepaid, addressed to: John M.Kerr,Esq. John Kerr Law P.0 5020 Ritter Rd.,#104 Mechanicsburg,PA 17055 Counsel for Defendant By: �---- ✓9 � "�" Fiona K. adness,Esq. RUSSELL FLUEVOG, : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA v. . NO. 6 q — p-5-5 I c e✓z I /C1" : CIVIL–DIVORCE 6 " PATRICIA FLUEVOG, Defendant • NOTICE TO DEFEND You have been sued in Court.If you wish to defend against the claims set forth in the following pages,you must take prompt action.You are warned that if you fail to do so,the case may proceed without you and a decree of divorce or annulment may be entered against you by the court.A judgment may also be entered against you for any other claim or relief requested in these papers by the plaintiff. You may lose money or property or other rights important to you, including custody or visitation of your children. When the ground for divorce is indignities or irretrievable breakdown of the marriage,you may request marriage counseling.A list of marriage counselors is available in the Office of the Prothonotary at the first floor in the Cumberland County Courthouse, 1 Courthouse Square,Carlisle, Pennsylvania. IF YOU DO NOT FILE A CLAIM FOR ALIMONY,DIVISION OF PROPERTY,LAWYER'S FEES OR EXPENSES BEFORE A DIVORCE OR ANNULMENT IS GRANTED,YOU MAY LOSE THE RIGHT TO CLAIM ANY OF THEM. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. CUMBERLAND COUNTY LAWYER REFERRAL SERVICE 32 South Bedford Street Carlisle,Pennsylvania 17013 Telephone(717)249-3166 RUSSELL FLUEVOG, : IN THE COURT OF.COMMON PLEAS Plaintiff : CUMBERLAND COUNTY,PENNSYLVANIA v. : NO. - vSs( : CIVIL—DIVORCE PATRICIA FLUEVOG, • Defendant COMPLAINT IN DIVORCE AND NOW,comes the Plaintiff, Russell Fluevog,by his attorney,John M.Kerr,Esquire, pursuant to Section 3301(c)&3301(d)of the Pennsylvania Divorce Code,and seeks to obtain a Decree in Divorce from the Defendant,Patricia Fluevog,upon the grounds set forth: COUNT I—NO-FAULT DIVORCE UNDER§§3301(c)or 3301(d) 1. The Plaintiff, Russell Fluevog,is an adult individual residing at 14 Sunset Drive, Mechanicsburg,Cumberland County,Pennsylvania 17050. 2. The Defendant,Patricia Fluevog,is an adult individual residing at 6 Wagner Drive, Mechanicsburg,Cumberland County,Pennsylvania 17050. 3. Plaintiff and Defendant have been bona fide residents of the Commonwealth of Pennsylvania for at least six(6)months immediately prior to the filing of this Complaint. 4. The Plaintiff and Defendant were married on August 28,2004 in Carlisle, Pennsylvania. yoo�a 5. Plaintiff separated from Defendant on November 27,2009. �hn M. err 5020 Mar Road 6. There have been no prior actions of divorce or annulment between the parties in this or Suite 109 Ma31Btr6burg.PA 17055 PHONS: 717.788.4008 Pm: 717.768.4068 any other jurisdiction. 7. The Plaintiff and Defendant are both citizens of the United States of America. 8. The Defendant is not a member of the United States Armed Forces. 9. The cause of action and section of Divorce Code under which Plaintiff is proceeding is that the marriage is irretrievably broken under 23 Pa.Const.Stat.§3301(c)or 3301(d). 10. Plaintiff requests this Honorable Court to enter a decree of divorce pursuant to Section 3301(c)or 3301(d)of the Divorce Code. WHEREFORE, it is requested that the Court enter a decree of divorce under either§§ 3301(c)or 3301(d)of the Divorce Code. Respectfully submitted, J. n M. Kerr, Esquire ID.#26414 Law Office of John M.Kerr,Esquire 5020 Ritter Road Suite 109 Mechanicsburg,PA 17055 (717)766-4008 kerrlaw @comcast.net Dated:December 11,2009 M. err 150-201:thter woad Sane 109 MOCheacsburg,PA 17065 Pty: 717.766.4008 F.x: 717.766.4066 • VERIFICATION The undersigned hereby states that he is the Plaintiff in the foregoing Divorce Action and,as such,is authorized to execute this Verification,and that any factual statements contained in the preceding Complaint in Divorce are true and correct to the best of his knowledge, information and belief. He understands that any false statements are subject to the penalties prescribed at 18 Pa.C.S.§4904, relating to unsworn falsification to authorities. 4,/ Russell Fluevog (1 FitED-oRtc,E -ma,/ 0F 41 9 DEC 1 PM 12' 19 tir $ 35) 66 64- 1 L1 ) /0 �-� a-3 y S John M. Kerr, Esquire John Kerr Law, PC 3 DEC 19 PM 2: ?7 5020 Ritter Road aw 1.'ik fBERLAND CHN( ' Suite 104 PENNSYLVANIA Mechanicsburg, PA 17055 Telephone: 717-766-4008 Facsimile: 717-766-4066 john @johnkerrlawpc.com Attorney for Plaintiff RUSSELL FLUEVOG, IN THE COURT OF COMMON PLEAS Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA V. NO. 2009-8551 CIVIL ACTION— DIVORCE PATRICIA FLUEVOG, Defendant PRAECIPE TO WITHDRAW COMPLAINT IN DIVORCE To: David Buell, Prothonotary Kindly withdraw the above-referenced divorce action. Respectfully submitted, JOHN KERR LAW, P.C. December 18, 2013 �4 YX &Z Jckn M. Kerr, Esquire Attorney for Plaintiff s CERTIFICATE OF SERVICE The undersigned hereby certifies that he has served a copy of the foregoing Praecipe to Withdraw Complaint by US First Class Mail, Postage Prepaid as follows: Fiona K. Fadness, Esquire 212 Barnett Street New Bloomfield, PA 17068 December 18, 2013 John M. Kerr, Esquire 3 ' F r L: •) J.. i- ;Eti<< l4J I t.L RUSSELL ANDREW FLUEVOG : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. :NO. 2009-8551 CIVIL TERM PATRICIA ANN FLUEVOG, : CIVIL ACTION -LAW Defendant : IN DIVORCE ORDER OF COURT AND NOW, this 1714 day of t 4 , 2013, upon consideration of Petitioner/Defendant, Patricia Ann Fluevog' s Petition for Reinstatement of Divorce Action, it is hereby ORDERED AND DECREED that said Petition is granted and the Divorce Action No. 2009-8551 is Reinstated. • BY COURT• J. 649/4" 441!:,:r .�O RUSSELL ALAN FLUEVOG, v. : IN THE COURT OF COMMON PLEAS Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-5662 CIVIL (CUSTODY) PATRICIA ANN FLUEVOG, NO. 2009-8551 CIVIL (DIVORCE) Defendant JUDGE GUIDO ORDER OF COURT AND NOW, this 29TH day of APRIL, 2014, a Rule is issued upon Plaintiff to Show Cause why the Motion to Withdraw as counsel should not be granted. Rule returnable twenty (20) days after service. M. Kerr, Esquire K. Fadness, Esquire /fussell A. Fluevog —■61ildren's Advocacy Clinic :sld 9/iy fl/Yi Edward E. Guido, J. C"-■ RUSSELL ANDREW FLUEVOG Plaintiff v. IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA : NO. 2009-8551 CIVIL TERM PATRICIA ANN FLUEVOG, : CIVIL ACTION - LAW Defendant : IN DIVORCE NOTICE If you wish to deny any of the statements set forth in this affidavit, you must file a counter -affidavit within twenty days after this affidavit has been served on you or the statements will be admitted. AFFIDAVIT UNDER SECTION 3301(d) OF THE DIVORCE CODE 1. The parties to this action separated on or about August 31, 2011 and have continued to live separate and apart for a period of at least two years. 2. The marriage is irretrievably broken. 3. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to autho Date: . i - / Cr1CO -r rri ▪ m ^ - -< ; CI) ci PATRICIA ANN FLUEVOG, DEFENDANg • CD c�- ry CA) RUSSELL ANDREW FLUEVOG : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA c: cl - -4 n) -vim y 7r1- PATRICIA ANN FLUEVOG, : CIVIL ACTION - LAW zAcri ,+F Defendant : IN DIVORCE r- — o -ac -11 zc cD; r z ., v. : NO. 2009-8551 CIVIL TERM AFFIDAVIT OF CONSENT 1. A Complaint in Divorce under section 3301(c) of the Divorce Code was filed on December 11, 2009. 2. The marriage of the Plaintiff and Defendant is irretrievably broken and more than ninety (90) days have elapsed from the date of filing the Complaint. 2. I consent to the entry of a final decree in divorce. 4. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 5. I understand that the costs of these proceedings will be paid for by Plaintiff. I verify that the statements made in this affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. Section 4904 relating to unsworn falsification to authorit' Date: 5-- 4- /y ATRICIA 'NN OG RUSSELL ANDREW FLUEVOG : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA v. PATRICIA ANN FLUEVOG, Defendant : NO. 2009-8551 CIVIL TERM : CIVIL ACTION - LAW : IN DIVORCE WAIVER OF NOTICE OF INTENTION TO REQUEST ENTRY OF A DIVORCE DECREE UNDER SECTION 3301(c) OF THE DIVORCE CODE 1. I consent to the entry of a final decree of divorce without notice. 2. I understand that I may lose rights concerning alimony, division of property, lawyer's fees or expenses if I do not claim them before a divorce is granted. 3. I understand that I will not be divorced until a divorce decree is entered by the Court and that a copy of the decree will be sent to me immediately after it is filed with the prothonotary. I verify that the statements made in this Affidavit are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities. Date: 5-9_ ie.( RI AN EVOG 3 r� Z rri 3 r r-- 33 --c 7'4 -ti .-<>' Q1 C) I r-- = CD "'® CD - = �c-.�+.. ^�` = , >c I V ` Y —4 y—� V - John M. Kerr, Esquire John Kerr Law, PC 5010 Ritter Road Suite 109 Mechanicsburg, PA 17050 Telephone: 717-766-4008 Facsimile: 717-766-4066 john@johnkerrlawpc.com RUSSELL A. FLUEVOG, Plaintiff vs. PATRICIA A. FLUEVOG, Defendant �.. -iJI' FEi.! THE PROTHONt7 lt? HAY 20 Psi 1: 06 CUMBERLAND COUNT Y PENNSYLVANIA IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA No.: 2009-8551 CIVIL (Divorce) PRAECIPE TO WITHDRAW TO: David Buell, Prothontary Kindly withdraw the appearance of John M. Kerr, Esquire and John Kerr Law, P.C. as counsel for Plaintiff, Russell A. Fluevog. A copy of the Order entered by the Honorable Edward E. Guido permitting said withdrawal, is attached hereto and marked as Exhibit "A." Respectfully submitted, JOHN KERR LAW, P.C. May 27, 2014 lel. /47,/ Jo / M. Kerr, Esquire PA ID No. 26414 5010 Ritter Road Suite 109 Mechanicsburg, PA 17055 Telephone: 717-766-4008 Facsimile: 717-766-4066 john@johnkerrlawpc.com RUSSELL A. FLUEVOG, Plaintiff IN THE COURT OF COMMON PLEAS, CUMBERLAND COUNTY, PENNSYLVANIA vs. No.: 2009-5662 CIVIL (Custody) No.: 2009-8551 CIVIL (Divorce) PATRICIA A. FLUEVOG, Defendant ORDER AND NOW, this 2veSt day of May, upon on consideration of the within Motion to Make Rule Absolute, it is ORDERED, ADJUDGED, and DECREED, John M. Kerr, Esquire and John Kerr Law, P.C. shall be permitted to withdraw as counsel to Russell A. Fluevog. Distribution: John M. Kerr, Esquire 5010 Ritter Road, Suite 109, Mechanicsburg, PA 17055 Fiona K. Fadness, Esquire 212 Barnett Street, New Bloomfield, PA 17068 , J. Lucy Johnston -Walsh, Esquire Children's Advocacy Clinic; 371 West South Street, Carlisle, PA 17013 Russell A. Fluevog 6 Wagner Drive, Mechanicsburg, PA 17050 3 - r - C- D EXHIBIT A CERTIFICATE OF SERVICE The undersigned hereby certifies that he has served a copy of the foregoing Praecipe to Withdraw via US First Class Mail, Postage Prepaid as follows: Fiona K. Fadness, Esquire 212 Barnett Street New Bloomfield, PA 17068 Lucy Johnston -Walsh, Esquire Children's Advocacy Clinic 371 West South Street Carlisle, PA 17013 Russell A. Fluevog 6 Wagner Drive Mechanicsburg, PA 17050 May 27, 2014 M. Kerr, Esquire